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Smaller players and innovative building materials suppliers may struggle to access and develop EPDs for their products.

There are emerging incentives for the development of Environmental Product Declarations (EPDs) in Australia as well as potential gaps in the EPD market that need to be addressed.

Australia’s market for sustainable building materials and low carbon project outcomes is ever growing. The introduction of the NABERS embodied carbon rating tool under development is the next step in driving reductions in carbon across commercial projects. The way the voluntary rating tool is designed will have a major impact on the direction the market heads in delivering sustainable outcomes.

Embodied carbon is the total greenhouse emissions generated during the manufacture, transport, and assembly of materials and products, and it is a complicated space for many reasons.

For one, processes for measuring embodied carbon and data availability are developing alongside the market for lower embodied carbon products. Data lacunas [missing data] present a challenge for accurately appraising carbon cost, and there is a mixture of different measurement methodologies employed along a project lifecycle to optimise outcomes.

The NABERS embodied carbon rating tool currently implements a series of incentive structures supporting the use of EPDs.

Materials without EPDs are attributed an embodied carbon estimate based on the industry worst for that class, plus an additional 5-20 per cent depending on data available. This means that using EPDs that are accurate can significantly lower the carbon profile of the material.

The NABERS tool is guaranteed to drive the uptake of EPDs in Australia as developers strive to deliver more sustainable projects. That is absolutely a good thing. EPDs provide product specific data that allows off-takers users to evaluate different manufacturers and their capacity for change.

Not so good for small innovative players

However, weighting EPDs so heavily could also have negative ramifications for certain parts of the marketplace.

Smaller players and innovative building materials suppliers may struggle to access and develop EPDs for their products. With such a heavy weighting in favour of EPDs, these sections of industry might suffer unless there are some interventions. The cost of EPDs are still prohibitive for many smaller suppliers, and there is a current shortage of life cycle practitioners in Australia able to deliver them.

For example, let’s consider two materials that won the Materials Embodied Carbon Leaders’ Alliance Innovative Building Materials Challenge in 2023: hemp and bamboo.

The hemp industry in Australia is estimated to quadruple by 2027 to $18.6 billion. New suppliers are emerging around Australia and while hemp has historically been used predominantly in residential developments, commercial interest in the material is growing.

Klara Marosszeky, chief executive officer of Australian Hemp Masonry said her association was developing the market but there was much work still to do.

 “We’re working with a new crop and an emerging industry,” She said

“There is no established carbon methodology for above ground sequestration with hemp. There is no Australian data yet on soil carbon sequestration although this work is underway. So, we’re still at a stage where we need to rely on European data.”

The traceability of all data relating to the farming of hemp is crucial, and although tools are being developed they are yet to arrive at market. So, alongside the financial barrier, there are still gaps in the analysis of the carbon aspects of hemp in these early stages of the market.

“It’s very tricky finding the balance between paying fees to multiple bodies for different kinds of recognition, testing and certifications to enhance marketability and staying viable and true to environmental or sustainability objectives especially in the early stages of an industry,” Marosszeky explained.

Similarly, bamboo is harvested within 5-7 years, and can replace a variety of emission intensive materials. It stores four  times more carbon dioxide than trees and produces 35 per cent more oxygen. It also has phytoremediating qualities, which enable it to leech contaminants out of soil, it can decrease soil erosion and prevent desertification.

Jennifer Snyders, CEO at House of Bamboo in Sydney, has been fighting to get Bamboo recognised in the Australian marketplace for decades. And she too identified cost as a potential barrier.

“If EPDs become a prerequisite for specifiers then it runs the risks of excluding small innovative companies with regenerative materials from the selection process, simply because they are unable to afford the process of attaining an EPD.”

Laura Hamilton-O’Hara, CEO of Living Future Institute of Australia, a strong advocate for biophilic design, echoes these sentiments, and highlights that small manufacturers’ ability to deliver on biophilic design components may be hamstrung if they cannot easily develop EPDs.

In other parts of the world government support has spurred f the development and accessibility of EPDs.

In the US, the Inflation Reduction Act dedicated $US250 million to technical assistance support to develop EPDs.

Meghan Lewis from the Carbon Leadership Forum says the IRA includes $US100 million in grants that will probably be awarded to trade associations for manufacturers to create infrastructure to cheaply make EPDs.

It also includes a labelling program driven by the Environmental Protection Agency recognising tiers of low and lower carbon products available in the marketplace.

Bridging the data gap is an important step in the Australian journey towards a more sustainable and lower carbon built environment. EPDs must be developed to accurately capture data, and it is good to see incentives introduced that drive those outcomes.

However, in this transitionary moment for the market we need to be sure mechanisms put in place do not put smaller players and innovative building material suppliers at risk, who also have a crucial role to play in our movement toward a decarbonised and more circular construction sector.

James Elks, head of product development at NABERS, presented on the development of their embodied carbon rating tool to Materials and Embodied Carbon Leaders Alliance and confirmed its  own advocacy across governmental departments for more support for EPD development.  

How we support the development of EPDs and make them more accessible is as important an aspect of the conversation as incentivising their use. If one happens without the other, we risk unintended systemic consequences. There is an opportunity for government to invest in the development of EPDs and support smaller manufacturers and innovative materials suppliers in their EPD journey. To best capture the green opportunity in materials for Australia we need to see this happen.


Monica Richter, WWF-Australia

Monica Richter is Senior Manager, Low Carbon Futures at WWF-Australia and Project Director at MECLA: Materials & Embodied Carbon Leaders’ Alliance. She encourages positive change in corporate behaviour around climate and energy. More by Monica Richter, WWF-Australia

Alexi Barnstone, MECLA

Alexi Barnstone is project manager at the Materials & Embodied Carbon Leaders’ Alliance (MECLA) More by Alexi Barnstone, MECLA

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  1. Anyone supplying building construction materials to the Australian market must provide certification of the product’s properties. Depending on the application this could include strength, fire resistance, acoustic and thermal properties, hardness and so on. Certification of these properties is often required by the National Construction Code for safety, amenity and environmental purposes. These requirements are often regarded as a barrier to new products but is that a bad thing? While environmental properties such as embodied carbon impacts are not (yet) a requirement of the NCC the market is asking for credible environmental impact data of products. Third-party verified EPDs can provide that credible date. Do they cost to get one for your product? Of course, it does. This isn’t a specific barrier for products made from simple natural materials. For example, Ortech Industries have recently registered their EPD for their Durra Panel product. Durra Panel is a wall and ceiling panel that contains an engineered biomass core made entirely out of reclaimed straw. It is also manufactured in Australia. Download it here: https://epd-australasia.com/epd/durra-panel/

  2. As anyone selling building construction products knows multiple certifications are required. Depending on the application this could be for fire resistance, strength, acoustic and thermal performance, moisture resistance, and so on. Often these are requirements of the National Construction Code. Environmental and embodied carbon data, while not an NCC requirement (yet), are no different. Ortech Industries manufactures Durra Panel – a wall and ceiling panel that contains an engineered biomass core made entirely out of reclaimed straw – in Bendigo, Victoria. They have recently had their third-party verified EPD published here https://epd-australasia.com/epd/durra-panel/. The market wants credible data and serious suppliers are providing it to support their claims.